"Does anyone know if SECURE 2.0 withdrawals are considered protected benefits? I find conflicting information. Some recordkeepers are enforcing it as protected benefits but I'm yet to see official guidance. I'm wondering how others are handling and/or interpreting this?"

" 'The Roth catch-up wage threshold for 2024, which under section 414(v)(7)(A) is used to determine whether an individual's catch-up contributions to an applicable employer plan (other than a plan described in section 408(k) or (p)) for 2025 must be designated Roth contributions, remains $145,000.' Why aren't they telling me today what the 2025 limit is, since this rule is first effective in 2026?"

"An owner-only DB Plan (husband and wife), has about $4,500,000 in assets. Part of the assets is a condo worth 1.5 million (they rent it out). They would like to invest further in real estate and have the plan purchase another condo, worth approx. 2 million, however the seller is willing to agree to sell it for 1.8. Is it advisable to purchase another RE Investment? It is in the same area as the first condo, so that might play a role in lack of diversification?"

"Our client joins a MEP with someone else effective (X) date -- let's just say November 10. Assets will be liquidated from current investment provider, and transferred into the MEP -- exactly how, not sure we care. My question is re the 5500SF. Is the 5500SF filed as a 'final' showing the transfer on Lines 13(b) and (c)? Or would it be a full year 5500SF since the plan isn't being 'terminated.' And would it be filed as a short plan year as of the date of transfer of the assets? It appears that no 5310-A would be required. Just not sure of the process. Would it just be the new MEP that would file a 5500 for 2024, and we wouldn't file a 5500 at all? It'll be driven by the new TPA anyway, but I'd like to get a better handle on how this typically is/should be handled."

"Cash balance plan -- Participant with a deferred vested benefit dies. Death certificate indicates the individual was divorced. When we are on notice of a divorce through the death certificate, we ask the estate or beneficiary to provide a divorce decree or separation agreement to determine if there is a possible QDRO that was just never presented to the plan. Often times, the divorce was decades prior to the death and the beneficiary is therefore unable to locate any divorce documentation. In these scenarios, does the plan sponsor have a fiduciary obligation to exhaustively seek out divorce documentation before paying benefit to estate/beneficiary? What happens if benefit is distributed to beneficiary and then ex-spouse comes forward with an old QDRO? For what it's worth the plan document does not directly address these situations. Would the same be true in scenarios where the participant divorced many years ago, they subsequently got remarried, and the benefit is payable to the new spouse. In these scenarios, the new spouse is almost never able to locate the divorce documentation."